RIGGIT N.

CHEATUM John Henry Doe

123 Shadylane Drive
Shadyville, California99999
File No,: 04-12345-0
SUPERIOR COURT OF CALIFORNIA
SAN JOAQUIN COUNTY, SHADYVILLE DIVISION
XYZ BANK (SB), N.A.
)
Case No. SV123456
Plaintiff,
)
vs
)
“LIMITED CIVIL MATTER”
JOHN H. DOE., ET AL.
)
Defendant,
)
ANSWER TO REQUEST FOR ADMISSIONS (SET ONE)
REQUESTING PARTY………PLAINTIFF, XYZ BANK (SB), N.A.
RESPONDING PARTY……...DEFENDANT, JOHN HENRY DOE.
1.You applied for and opened a credit card account with XYZ BANK (SB), N.A.

I am not in receipt of the testimony of a competent witness with first hand knowledge, nor am I in

receipt of any contract with my bonafied, original ink-signature, which prove such a contract was

ever formed. I AM in receipt of evidence that no contract was ever formed.

2. A MASTERCARD was issued to you by XYZ BANK (SB), N.A. with the account
number 5437000320931234.

I am not in receipt of the testimony of a competent witness with first hand knowledge, nor am I in

receipt of any contract with my bonafied, original ink-signature, which prove such a contract was

ever formed. I AM in receipt of evidence that no contract was ever formed. I am not in receipt of any

evidence which proves that XYZ BANK (SB), N.A. ever provided any consideration or put at risk its

funds for any “loan” to me.

3. You used the credit card and made charges and made payments to the account.
I am not in receipt of the testimony of a competent witness with first hand knowledge, nor am I
in receipt of any contract with my bonafied, original ink-signature, which prove such a contract

4.
Monthly statements were mailed to you at .123 Shadylane Drive, Shadyville, California
99999 indicating monthly debits, credit and payments made on the account.

I am not in receipt of the testimony of a competent witness with first hand knowledge, nor am I in

receipt of any contract with my bonafied, original ink-signature, which prove such a contract was

ever formed. JOHN H. DOE IS in receipt of evidence that no contract was ever formed. Moreover,
JOHN H. DOE offered to fully restore to XYZ BANK (SB), N.A. all funds actually put at risk by XYZ

BANK (SB), N.A., upon the condition that, inter alia, XYZ BANK (SB), N.A. do a full accounting

showing what assets had been put at risk by XYZ BANK (SB), N.A. . XYZ BANK (SB), N.A. declined

said offer of full restitution and declined to do the full accounting requested by JOHN H. DOE.

Therefore, any purported statements mailed to JOHN H. DOE indicating monthly debits, credit and

payments made on the account are moot, or else, after the tacit admission of fraud by XYZ BANK

(SB), N.A., said statements could be construed as evidence that XYZ BANK (SB), N.A. was

engaged in criminal conversion, seeing as how it never gave JOHN H. DOE any consideration, nor

put at risk any XYZ BANK (SB), N.A. funds 5.

You were mailed and received a Cardholder Agreement for this account.

I am not in receipt of the testimony of a competent witness with first hand knowledge, nor am I in

receipt of any contract with my bonafied, original ink-signature, which prove such a contract was

ever formed. XYZ BANK (SB), N.A. did not offer full disclosure in its standard application; did not

offer consideration to JOHN H. DOE.; did not provide JOHN H. DOE with an opportunity to cancel on

a seperate sheet as required by the Truth in Lending Act, which states that failure to provide said

opportuinty to cancel on a seperate sheet of paper renders purported contract a nullity ab initio.

Therefore no “meeting of the minds” ever took place and no contract was ever formed. JOHN H.

DOE IS in receipt of evidence that no contract was ever formed.

If you cannot answer (i.e. don't know how to answer) an interrogatory, you can use the
following:

I conditionaly accept your offer to have me answer this question upon proof of claim that you have

complied with all requirements of the fair debt collection practices Act 15 USC SECT 1692 et. seq, to

wit; that you have produced the contract with my ink signature upon it which is the basis of your

claim, and, the sworn testamony of a competent witness with first hand knowledge who can testify

as to where the funds for the purported loan originated; that the plaintiff put at risk